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Filing # 65752919 E-Filed 12/22/2017 12:06:05 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL
CIRCUIT, IN AND FOR, ORANGE COUNTY,
FLORIDA
CASE NO: 2017-CA-003987-O
LORRAINE BRADSHAW,
Plaintiff,
vs.
ALLSTATE FIRE AND CAUSALTY
INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S DISCLOSURE OF EXPERT WITNESSES
COMES NOW the Plaintiff, LORRAINE BRADSHAW, by and through her undersigned
counsel and in compliance with this Honorable Court's September 29, 2017, Uniform Order Setting
Case For Jury Trial And Directing Pre-Trial Procedure, provides the following disclosure of expert
witnesses anticipated to testify at the trial of this action:
1. Any and all medical providers/personnel at:
Batson Family Health and Wellness Center
450 West State Road 434, Suite 2010
Longwood, FL 32750
(407) 331-7010
Medical field of expertise: Emergency/ General Medicine.
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff.
2. Francis Brooks, DO / any and all medical providers/personnel at:
Florida Impairment, LLC
483 N Semoran Blvd Suite 104
Winter Park, FL 32792
Medical field of expertise: General Medicine.
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and
treatment records (past and present); causation and permanency of injuries.
3. Stephanie Baker, PT, MS, CSCS / any and all medical providers/personnel at:
Envision Physical Therapy
956 International Parkway, Suite 1580
Lake Mary, FL 32746
(407) 936-0314
Medical specialty: Physical Therapy
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and
treatment records (past and present); causation and permanency of injuries.
4. Stephanie Blair, DPT / any and all medical providers/personnel at:
Envision Physical Therapy
956 International Parkway, Suite 1580
Lake Mary, FL 32746
(407) 936-0314
Medical specialty: Physical Therapy
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and
treatment records (past and present); causation and permanency of injuries.
5. Jonathan C. Eugenio, MD / any and all medical providers/personnel at:
Emery Medical Solutions
2151 E. Semoran Blvd.
Apopka, FL 32703
(407) 628-9100
Medical specialty: Radiology/Diagnostics
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and
treatment records (past and present); causation and permanency of injuries.
6. Nizam Razack, MD / any and all medical providers/personnel at:
Spine and Brain Neurosurgery Center
7460 Doc's Grove Circle
Orlando, FL 32819
(407) 903-9360
Medical specialty: Neurology
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and
treatment records (past and present); causation and permanency of injuries.
7. Diana Hussain, MD / any and all medical providers/personnel at:
Spine and Brain Neurosurgery Center
7460 Doc's Grove Circle
Orlando, FL 32819
(407) 903-9360
Medical specialty: Physical Medicine and Rehabilitation Specialist
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and
treatment records (past and present); causation and permanency of injuries.
8. Frederick W. Hartker, MD / any and all medical providers/personnel at:
Central Florida Imaging Specialists
2222 S. Harbor City Blvd., Suite 520
Melbourne, FL 32901
Medical specialty: Radiology/Diagnostics/ Treating Physician
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and
treatment records (past and present); causation and permanency of injuries.
9. Sean M. Mahan, MD
Elite RAD Radiology Services
5840 Red Bug Lake Road, Ste 185
Winter Springs, FL 32708
(407) 699-1100
Medical specialty: Radiology/Diagnostics
Testifying Subject: Re-Read of Plaintiff’s MRI/X-ray(s) film(s), clinical history and
treatment records (past and present); causation and permanency of injuries.
The said above-listed experts are expected to testify in their respective fields of expertise
as to their medical care, treatment and or services rendered to Plaintiff, LORRAINE
BRADSHAW; including but not limiting their testimony to the issues of reasonableness and
necessity of care and treatment, as well as the issue of causation and permanency of the injuries.
In addition to the above areas of testimony, Dr. Sean Mahan will testify as an expert radiologists
and the scope of his testimony will include his expertise in the re-read of the Plaintiff’s
MRI(s)/x-ray(s)/diagnostic, clinical history, review of past and present treatment records, and as
a rebuttal witness of the Defense’s radiologist or medical expert.
The curriculum vitae of each above-listed expert witness has been requested and will be
furnished, if not already received and attached as composite exhibit hereto, to Defendant as soon
as the same has been made available to counsel for Plaintiff.
1. As Plaintiff’s treatment for his incident-related injuries is ongoing, Plaintiff reserves the
right to identify, as expert witnesses, any additional health care providers who render
treatment to Plaintiff for accident-related injuries that become known prior to the
discovery cut-off date in this action.
2. Any expert witnesses discovered in formal discovery prior to the discovery cut-off date in
this action.
3. Any other applicable expert witness necessary to authenticate any exhibit listed on the
Plaintiff’s Exhibit List.
4. Any witness listed by the Defendant to this cause in their Expert Witness Lists previously
filed or to be filed.
5. Any expert witness who rendered deposition testimony in the discovery of this cause of
action.
6. Any expert witnesses discovered in formal discovery prior to the discovery cut-off date of
this cause.
7. Any and all expert witnesses listed or retained by the Defendant, whether formally listed,
withdrawn as expert witnesses and regardless of whether called at trial by the Defendant, or
later withdrawn by the Defendant.
8. Any and all compulsory medical examiners of the Defendant and/or any and all later or
additionally disclosed compulsory medical examiners, whether formally listed on
Defendant’s expert witness list and/or withdrawn as expert witnesses by the Defendant.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 22, 2017, I electronically filed the foregoing
with the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that
Pursuant to Rule 2.516(b)(1) I forwarded the foregoing this same day via: â– Email, to: Michelle
Gerjel, Esquire, Law Offices of Robert J. Smith, 390 North Orange Avenue, Suite 895, Orlando,
FL 32801-1635; [orlandolegal@allstate.com].
/s/Lawrence Gonzalez II
Lawrence Gonzalez II, Esquire
FBN 0107175
Morgan & Morgan, P.A.
20 N. Orange Ave., 16th Floor
P.O. Box 4979
Orlando, FL 32802-4979
Telephone: (407) 418-2076
Facsimile: (407) 572-0110
Primary email: LGonzalez@forthepeople.com
Secondary email: SSerrano@forthepeople.com
DMessina@forthepeople.com
Attorneys for Plaintiff
Preview
Filing # 65752919 E-Filed 12/22/2017 12:06:05 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR, ORANGE COUNTY, FLORIDA CASE NO: 2017-CA-003987-O LORRAINE BRADSHAW, Plaintiff, vs. ALLSTATE FIRE AND CAUSALTY INSURANCE COMPANY, Defendant. / PLAINTIFF’S DISCLOSURE OF EXPERT WITNESSES COMES NOW the Plaintiff, LORRAINE BRADSHAW, by and through her undersigned counsel and in compliance with this Honorable Court's September 29, 2017, Uniform Order Setting Case For Jury Trial And Directing Pre-Trial Procedure, provides the following disclosure of expert witnesses anticipated to testify at the trial of this action: 1. Any and all medical providers/personnel at: Batson Family Health and Wellness Center 450 West State Road 434, Suite 2010 Longwood, FL 32750 (407) 331-7010 Medical field of expertise: Emergency/ General Medicine. Testifying Subject: Treating physician(s)/provider(s) of Plaintiff. 2. Francis Brooks, DO / any and all medical providers/personnel at: Florida Impairment, LLC 483 N Semoran Blvd Suite 104 Winter Park, FL 32792 Medical field of expertise: General Medicine. Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and treatment records (past and present); causation and permanency of injuries. 3. Stephanie Baker, PT, MS, CSCS / any and all medical providers/personnel at: Envision Physical Therapy 956 International Parkway, Suite 1580 Lake Mary, FL 32746 (407) 936-0314 Medical specialty: Physical Therapy Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and treatment records (past and present); causation and permanency of injuries. 4. Stephanie Blair, DPT / any and all medical providers/personnel at: Envision Physical Therapy 956 International Parkway, Suite 1580 Lake Mary, FL 32746 (407) 936-0314 Medical specialty: Physical Therapy Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and treatment records (past and present); causation and permanency of injuries. 5. Jonathan C. Eugenio, MD / any and all medical providers/personnel at: Emery Medical Solutions 2151 E. Semoran Blvd. Apopka, FL 32703 (407) 628-9100 Medical specialty: Radiology/Diagnostics Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and treatment records (past and present); causation and permanency of injuries. 6. Nizam Razack, MD / any and all medical providers/personnel at: Spine and Brain Neurosurgery Center 7460 Doc's Grove Circle Orlando, FL 32819 (407) 903-9360 Medical specialty: Neurology Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and treatment records (past and present); causation and permanency of injuries. 7. Diana Hussain, MD / any and all medical providers/personnel at: Spine and Brain Neurosurgery Center 7460 Doc's Grove Circle Orlando, FL 32819 (407) 903-9360 Medical specialty: Physical Medicine and Rehabilitation Specialist Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and treatment records (past and present); causation and permanency of injuries. 8. Frederick W. Hartker, MD / any and all medical providers/personnel at: Central Florida Imaging Specialists 2222 S. Harbor City Blvd., Suite 520 Melbourne, FL 32901 Medical specialty: Radiology/Diagnostics/ Treating Physician Testifying Subject: Treating physician(s)/provider(s) of Plaintiff, clinical history and treatment records (past and present); causation and permanency of injuries. 9. Sean M. Mahan, MD Elite RAD Radiology Services 5840 Red Bug Lake Road, Ste 185 Winter Springs, FL 32708 (407) 699-1100 Medical specialty: Radiology/Diagnostics Testifying Subject: Re-Read of Plaintiff’s MRI/X-ray(s) film(s), clinical history and treatment records (past and present); causation and permanency of injuries. The said above-listed experts are expected to testify in their respective fields of expertise as to their medical care, treatment and or services rendered to Plaintiff, LORRAINE BRADSHAW; including but not limiting their testimony to the issues of reasonableness and necessity of care and treatment, as well as the issue of causation and permanency of the injuries. In addition to the above areas of testimony, Dr. Sean Mahan will testify as an expert radiologists and the scope of his testimony will include his expertise in the re-read of the Plaintiff’s MRI(s)/x-ray(s)/diagnostic, clinical history, review of past and present treatment records, and as a rebuttal witness of the Defense’s radiologist or medical expert. The curriculum vitae of each above-listed expert witness has been requested and will be furnished, if not already received and attached as composite exhibit hereto, to Defendant as soon as the same has been made available to counsel for Plaintiff. 1. As Plaintiff’s treatment for his incident-related injuries is ongoing, Plaintiff reserves the right to identify, as expert witnesses, any additional health care providers who render treatment to Plaintiff for accident-related injuries that become known prior to the discovery cut-off date in this action. 2. Any expert witnesses discovered in formal discovery prior to the discovery cut-off date in this action. 3. Any other applicable expert witness necessary to authenticate any exhibit listed on the Plaintiff’s Exhibit List. 4. Any witness listed by the Defendant to this cause in their Expert Witness Lists previously filed or to be filed. 5. Any expert witness who rendered deposition testimony in the discovery of this cause of action. 6. Any expert witnesses discovered in formal discovery prior to the discovery cut-off date of this cause. 7. Any and all expert witnesses listed or retained by the Defendant, whether formally listed, withdrawn as expert witnesses and regardless of whether called at trial by the Defendant, or later withdrawn by the Defendant. 8. Any and all compulsory medical examiners of the Defendant and/or any and all later or additionally disclosed compulsory medical examiners, whether formally listed on Defendant’s expert witness list and/or withdrawn as expert witnesses by the Defendant. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 22, 2017, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that Pursuant to Rule 2.516(b)(1) I forwarded the foregoing this same day via: ■Email, to: Michelle Gerjel, Esquire, Law Offices of Robert J. Smith, 390 North Orange Avenue, Suite 895, Orlando, FL 32801-1635; [orlandolegal@allstate.com]. /s/Lawrence Gonzalez II Lawrence Gonzalez II, Esquire FBN 0107175 Morgan & Morgan, P.A. 20 N. Orange Ave., 16th Floor P.O. Box 4979 Orlando, FL 32802-4979 Telephone: (407) 418-2076 Facsimile: (407) 572-0110 Primary email: LGonzalez@forthepeople.com Secondary email: SSerrano@forthepeople.com DMessina@forthepeople.com Attorneys for Plaintiff